United States First Circuit

In an appeal of a tax court decision affirming a determination by the Commissioner of the Internal Revenue Service (IRS) that he owed $3.790 million in income taxes and penalties on $5.65 million in bank deposits petitioner made and interest earned from 1995 to 2002, the tax court determination is affirmed over petitioner's contentions that these deposits were not his taxable personal income but the program income of a social welfare organization that had tax-exempt status pursuant to section 501(c)(4) of the Internal Revenue Code, 26 U.S.C. section 501(c), where an organization distinct from petitioner did not exist during the applicable tax years.

Appellate Information

• Published 2016/09/13

Judges

• TORRUELLA

Court

• United States First Circuit

Counsel